program for National Governing Bodies for Olympic,Paralympic, and Pan-American Games Sports.3.Defendant Travis Tygart is a resident of the state of Colorado. Mr. Tygart is named as a Defendant in his officialcapacity as the Chief Executive Officer (“CEO”) of USADA,with his principal place of business at 5555 Tech Center Drive,Suite 200, Colorado Springs, Colorado 80919.
Nature of Action
4.Mr. Armstrong brings this Complaint against USADA andits CEO, Travis Tygart, to prevent imminent violations of Mr.Armstrong’s Constitutional and common law due process rights, by which the Defendants would strip Mr. Armstrong of hislivelihood, his seven
Tour de France
titles, and the many other honors he has won in his world-renowned cycling career.5.Defendants’ actions demonstrate their belief that USADA isabove the United States Constitution, above the law, above courtreview, free from supervision from any person or organization,and even above its own rules. Defendants will no doubt tell thisCourt it has no power or authority either to review their conductor force USADA to obey the law, obey the Constitution or evenobey its own rules. Contrary to Defendants’ belief that USADAanswers to no one outside of an arbitration regime it has created2